Arden Transport Precinct - Arden Structure Plan - Amenity Risk Assessment Victorian Planning Authority 23 August 2021 - Engage Victoria
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Arden Transport Precinct
Arden Structure Plan – Amenity Risk
Assessment
Victorian Planning Authority
23 August 2021
The Power of Commitment
GHD Pty Ltd | ABN 39 008 488 373
180 Lonsdale Street, Level 9
Melbourne, Victoria 3000, Australia
T 61-3-8687 8000 | F 61-3-8732 7046 | E melmail@ghd.com | ghd.com
Document status
Status Revision Author Reviewer Approved for issue
Code
Name Signature Name Signature Date
Draft A 27/04/2021
S4 0 S.Materia M.Asimakis B.George 23/08/2021
© GHD 2021
This document is and shall remain the property of GHD. The document may only be used for the purpose for
which it was commissioned and in accordance with the Terms of Engagement for the commission. Unauthorised
use of this document in any form whatsoever is prohibited.
The Power of Commitment
Executive summary
GHD was engaged by the Victorian Planning Authority (VPA) to provide advice regarding the management of
adverse amenity impacts in the Arden Transport Precinct (the Precinct).
Work undertaken by GHD in 2019 identified four businesses with a separation distance in accordance with the
EPA separation distance guideline1 (EPA Publication 1518) that affect the Precinct (i.e. in direct conflict with the
proposed future urban structure of the Precinct which includes a proposed hospital, proposed primary school and
residential dwellings).
The four industries include:
– Citywide – Asphalt plant (500 m separation distance)
– Holcim – Concrete batching plant (100 m separation distance)
– Irwin Stockfeeds – Grain and stockfeed mill and handling facility (250 m separation distance)
– Weston Milling – Flour mill (250 m separation distance)
GHD was subsequently engaged to provide further advice regarding the management of adverse amenity impacts
in the Precinct. In accordance with the ‘agent of change’ principle outlined in EPA Publication 1518 an assessment
was undertaken to investigate if a variation of the default separation distances was appropriate. Through a
combination of a qualitative risk assessment (Source-Pathway-Receptor concept) and fieldwork investigation
(odour surveillance), GHD investigated the potential to vary the separation distances of the four identified
industries and the subsequent risk they pose to amenity within the Precinct as proposed.
Risk Assessment Outcomes
Source-Pathway-Receptor assessment
The S-P-R concept allows for a prediction of the odour or dust impact based on the ‘magnitude of source release,
the effectiveness of the pathway and sensitivity of the receptor’. The S-P-R assessment focused on upset events
occurring and the emission controls and management procedures in place to mitigate such events from having an
impact offsite.
The outcome of S-P-R risk assessment indicated the overall level of risk from each of the four industries varies
from Low for Holcim, Weston Milling and Irwin Stockfeeds to Medium for Citywide. The overall risk is considered to
apply to the entire recommended separation distance for each industry given that the separation distances are
designed to protect against off-site emissions in the event of an upset.
The results indicate that sensitive uses can be implemented within the separation distances of Holcim, Weston
Milling and Irwin Stockfeeds. For Citywide, the implementation of sensitive uses may be acceptable if controls are
in place. Control of air quality emissions through built form is one example.
From information provided by Holcim, GHD understands that the concrete batching plant is a temporary facility
which is to be de-commissioned when it will be no longer be required for Metro tunnel construction purposes.
Thus, the 100 m separation distance identified, and the subsequent low risk will not apply after decommissioning.
Given the assessment concerns existing industries, empirical observations are possible of what is happening on
the ground within the Precinct, and therefore considerable weight should be given to the observational findings of
community-based tools such as complaints analysis and odour surveillance programs. The S-P-R risk outcomes
were therefore adjusted to account for the empirical evidence.
1
EPA Publication 1518 dated March 2013
The Power of Commitment i
Complaint history
EPA sent through an updated complaint history from 2013 until April 2021. A total of fifteen odour complaints
alleging odour from Citywide were provided. Of most interest, is the period from the end of 2018 when Citywide
installed a large odour control upgrade their site. There were only two odour complaints from 2019 and 2020
combined. With regards to dust there were three complaints attributed to Weston Milling, two for Melbourne Metro
Tunnel and one for Irwin Stockfeeds. GHD was unable to verify the sources of the complaints. However, from the
existing residential locations within the Precinct there have only been two dust complaints (assumed to be in
relation to Weston Miling’s upset in 2013 along Muster Terrace), one in relation to Irwin Stockfeeds, no other dust
or odour (since 2019) complaints have been recorded in the existing residential locations (see section 2.4 for
locations of existing residential receptors). There has also been an increase in sensitive uses in the Precinct with
the introduction of the Woolworths development (Corner of Macaulay Road and Vaughan Terrace in North
Melbourne) which has not resulted in an increase in complaints. This suggests that the industries are not
generating odour or dust reports in nearby residential areas within the recommended separation distances.
Odour surveillance
GHD undertook 10 odour surveys in accordance with the EPA odour surveillance guidance.
Odour was observed from two of the identified industries, namely, Citywide and Irwin Stockfeeds. Odour from
Citywide was observed in the surrounding area (e.g. on Arden Street, Green Street etc.), whereas odour from Irwin
Stockfeeds was not observed beyond the property boundary.
Updated risk accounting for Empirical evidence
Based on the results of the odour surveillance, GHD increased a portion of the medium risk zone to moderate risk
for the Citywide facility as obvious odour was detected out to a maximum distance of 152 m. Beyond 152 m GHD
did not detect any obvious odour, with subtle odour being detected out to a maximum distance of 377 m. No
change to the S-P-R risk categorisation was required for subtle odour observations, therefore medium risk
remained from 152 m to 377 m.
Given that no odour was detected beyond 377 m, GHD reduced the risk categorisation from medium to low to give
a greater weight to the empirical evidence. The reduction to low risk beyond 377 m is also supported by the
complaint history, with a lack of complaints from the existing receptors located within the recommended separation
distance.
No obvious odours were detected off-site in relation to the other three industries (Holcim, Weston Milling and Irwin
Stockfeeds) therefore the S-P-R risk categorisation remained unchanged. Given the S-P-R risk categorisation was
low for these three industries, GHD left the risk unchanged at low even with the lack of complaints from within the
separation distances.
Meteorology
No further adjustments due to meteorology were made to the distances informing the zones of risk, given that they
have already accounted for local wind regimes through the odour surveillance campaign. A conservative approach
has been adopted taking the maximum distance detected to inform the zones of risk.
Future land use planning considerations
It is assumed that the development of the site will occur incrementally over time, and therefore it is important that
the management of the transition from existing to proposed land uses minimises short term impacts of non-
compatible uses.
GHD recommends the use of planning controls to assist with the future land use planning of the Precinct, namely:
– Use of interface land uses
– Setback strategy
– Staged development
– Control of odour and dust emissions through built form
– Implementation of application requirements for sensitive uses
The Power of Commitment ii
From the results of the risk assessment, areas of low and medium risk are considered to be more suitable for the
introduction of sensitive uses (subject to mitigation measures being implemented at the receptor for the medium
risk areas such as building design controls). For moderate risk areas, sensitive uses are not recommended until
controls are implemented at source and receptor. While for high risk areas, sensitive uses are recommended to be
prohibited until such time that the industry ceases to operate.
A map of the final risk assessment results taking into account empirical evidence is provided below.
The Power of Commitment iii
Contents
Executive summary i
1. Introduction 1
1.1 Context 1
1.2 Purpose of this report 1
1.3 Scope of works 2
1.4 Scope of limitations 2
1.5 Assumptions 3
2. Site overview 4
2.1 Location and land use 4
2.2 Surrounding land use 4
2.3 Sensitive land use 4
2.4 Constraining Industries 6
2.5 Proposed future urban structure 6
3. EPA Victoria Publication 1518 8
3.1 Overview 8
3.2 Purpose 8
3.3 Agent of change principle 9
3.4 Interface land uses 9
3.5 Application to the Precinct 9
4. Overview of Industries 11
4.1 Citywide Asphalt Plant 11
4.1.1 Operations and technology 11
4.1.2 Sources 11
4.1.3 Emission controls 12
4.1.4 Management 12
4.1.5 Upsets events 13
4.1.6 Upgrades/continual improvement/future plans 13
4.1.7 Complaints and EPA notices 13
4.1.8 GHD’s observations 14
4.1.9 Summary 14
4.2 Holcim Concrete Batching Plant 14
4.2.1 Operations and technology 15
4.2.2 Sources 15
4.2.3 Emission controls 15
4.2.4 Management 16
4.2.5 Upsets events 16
4.2.6 Upgrades/continual improvement/future plans 17
4.2.7 Complaints and EPA notices 17
4.2.8 GHD’s observations 17
4.2.9 Summary 17
4.3 Weston Milling 17
4.3.1 Operations and technology 17
4.3.2 Sources 18
4.3.3 Emission controls 18
The Power of Commitment iv
4.3.4 Management 18
4.3.5 Upsets events 19
4.3.6 Upgrades/continual improvement/future plans 19
4.3.7 Complaints and EPA notices 19
4.3.8 GHD’s observations 19
4.3.9 Summary 19
4.4 Irwin Stockfeeds 20
4.4.1 Operations and technology 20
4.4.2 Sources 20
4.4.3 Emission controls 20
4.4.4 Management 21
4.4.5 Upsets events 21
4.4.6 Upgrades/continual improvement/future plans 21
4.4.7 Complaints and EPA notices 21
4.4.8 GHD’s observations 22
4.4.9 Summary 22
5. Risk Assessment 23
5.1 Source-Pathway-Receptor Assessment 23
5.1.1 Methodology 23
5.1.2 Step 1: Categorise the type of source, pathway and receptor 25
5.1.3 Step 2: Estimate the risk of odour or dust exposure 31
5.1.4 Step 3: Determine the overall risk of odour or dust impact 32
5.1.5 Implication for the Precinct 33
5.1.6 Summary 35
5.2 Updated EPA complaint history 35
5.3 Odour surveillance 36
5.3.1 Survey methodology 36
5.3.2 Odour survey results 37
5.3.3 Updated risk accounting for empirical evidence 40
5.4 Meteorology 42
5.4.1 Prevailing winds 42
5.4.2 Directional buffer 43
5.4.3 Implication for the Precinct 43
5.5 Cumulative Impacts 43
5.6 Summary 43
5.6.1 Supporting evidence 44
6. Future land use planning considerations 45
6.1 Transitioning of the Industry 45
6.2 Interface land uses 45
6.3 Planning controls 46
6.3.1 Setback Strategy 46
6.3.2 Staged development 46
6.3.3 Control of air quality emissions through built form 46
6.3.4 Implementation of application requirements for sensitive uses 47
6.3.5 Odour/dust risk assessment criteria 48
The Power of Commitment v
Table index
Table 1 Description of risk ratings................................................................................... 25
Table 2 Source pathway receptor model application to the industries ............................. 26
Table 3 Risk of odour exposure matrix - Citywide ........................................................... 31
Table 4 Risk of odour exposure matrix- Holcim .............................................................. 31
Table 5 Risk of odour exposure matrix – Weston Milling ................................................ 31
Table 6 Risk of odour exposure matrix – Irwin Stockfeeds.............................................. 31
Table 7 Overall risk of Odour/ Dust Impact - Citywide..................................................... 32
Table 8 Overall risk of Odour/ Dust Impact - Holcim ....................................................... 32
Table 9 Overall risk of Odour/ Dust Impact – Weston Milling .......................................... 32
Table 10 Overall risk of Odour/ Dust Impact – Irwin Stockfeeds ....................................... 33
Table 11 Odour intensity descriptors ................................................................................ 36
Table 12 Odour duration descriptors ................................................................................ 36
Table 13 Summary of odour surveys ................................................................................ 38
Figure index
Figure 2-1 Site overview 5
Figure 2-2 Proposed Future Urban Structure (Provided by the VPA) 7
Figure 3-1 Criteria for site-specific variation (Table 4 of EPA Separation distance guideline)
9
Figure 5-1 Source-Pathway-Receptor risk 34
Figure 5-2 Summary of odour surveys 39
Figure 5-3 Updated risk accounting for empirical evidence 41
Figure 5-4 Annual wind rose – Footscray (6:00 am to 4:00 pm) 42
Appendices
Appendix A Odour survey results
The Power of Commitment vi
1. Introduction
1.1 Context
GHD was engaged by the Victorian Planning Authority (VPA) to provide advice regarding the management of
adverse amenity impacts in the Arden Transport Precinct (the Precinct). GHD understands that the VPA is
currently working to implement a structure plan for the Precinct.
The Precinct is located less than two kilometres from the Melbourne central city and adjacent to the established
suburbs of North Melbourne, Kensington, West Melbourne and the evolving mixed-use Macaulay urban renewal
precinct. GHD understands that the Precinct will transform underutilised industrial land into a world class urban
renewal precinct accommodating 34,000 jobs and 15,000 new residents by 2051. However, to deliver this
outcome, the VPA has sought further investigations to assist with the preparation of planning controls to implement
the structure plan via a planning scheme amendment.
The VPA has previously engaged the preparation of a desktop Adverse Amenity Impact Assessment of the
Precinct. This work was undertaken by GHD in 2019 (GHD 20192) and identified four businesses with a separation
distance in accordance with the EPA separation distance guideline3 (EPA Publication 1518) that affect the Precinct
(in direct conflict with the proposed future urban structure of the Precinct which includes a hospital, primary school
and residential dwellings).
The four industries are:
– Citywide – Asphalt plant - 208-292 Arden Street, North Melbourne
– Holcim - Concrete Batching Plant - 77 Laurens Street, North Melbourne
– Irwin Stockfeeds – Grain and stockfeed mill and handling facility - 1 Laurens Street, North Melbourne
– Weston Milling – Flour mill - 40 Laurens Street, North Melbourne
The establishment of compatible land uses and/or accommodating industrial uses in contemporary cities is an
increasingly significant issue in the development of urban areas, and presents a two-fold challenge:
– The risk of newly developed sensitive uses being subjected to unacceptable amenity impacts
– The encroachment of sensitive uses into the separation distance areas of existing industries which may result
in unachievable or commercially unreasonable constraints being required of the industries to mitigate the
impacts at the source (‘reverse amenity’)
Through a combination of a qualitative risk assessment and fieldwork investigation (odour surveillance), GHD has
investigated the possibility of varying the separation distances of the four identified industries and the subsequent
risk they pose to amenity within the Precinct.
It is noted that the assessment undertaken by GHD in this report relates to odour and dust amenity only, in line
with EPA Publication 1518. The purpose of a qualitative risk assessment is to maintain sufficient separation
between sensitive land uses (such as residences) and industries that have the potential to generate emissions of
nuisance dust and/or odour so that on the occasion of an upset or malfunction, the off-site adverse amenity is
minimised. This separation distance risk assessment utilises an assessment methodology in accordance with the
‘agent of change’ principle based on Section 9 of EPA Publication 1518, as agreed with EPA4.
1.2 Purpose of this report
The purpose of this report is to provide advice to the VPA regarding the management of adverse amenity impacts
in the Arden Transport Precinct. The report should be read in conjunction with the limitations and assumptions in
section 1.4 and 1.5 respectively.
2
GHD 2019, Arden Adverse Amenity Impact Assessment
3
EPA Publication 1518 dated March 2013
4
Meeting with EPA, VPA and DoT on 16 March 2021
GHD | Victorian Planning Authority | 12548247 | Arden Transport Precinct 1
1.3 Scope of works
This assessment was prepared in accordance with the following scope of works:
General
– Inception meeting held with the VPA, EPA and Department of Transport (DoT) to clarify and confirm
methodology, objectives, reporting, program and discuss any outstanding issues or queries.
– Request and review relevant information pertaining to each of the four identified industries.
– Site visits to inspect each of the four identified industries.
– Review of each industry’s operations including emission controls and management procedures in place.
Risk Assessment
– Undertake a qualitative risk-based assessment (for odour and dust) based on the Source-Pathway-Receptor
concept, to determine the relative risk of amenity impact.
– Based on the local meteorology, establish the likelihood and subsequent risk to amenity occurring during an
upset from the four identified industries at the Precinct.
– Conduct an odour surveillance program.
Reporting
– Review the recommended EPA separation distances for each industry and conclude whether there are
factors that would likely result in a variation to the separation distance.
– Provide conclusions as to the likely areas of risk to amenity (high, medium and low) within the Precinct (and
any mitigation needed).
– Provide recommendations on appropriate planning controls to manage the risk of adverse amenity to support
the introduction of sensitive uses while the Precinct is in transition.
1.4 Scope of limitations
This report has been prepared by GHD for the Victorian Planning Authority and may only be used and relied on by
Victorian Planning Authority for the purpose agreed between GHD and the Victorian Planning Authority as set out
in section 1.2 of this report.
GHD otherwise disclaims responsibility to any person other than Victorian Planning Authority arising in connection
with this report. GHD also excludes implied warranties and conditions, to the extent legally permissible.
The services undertaken by GHD in connection with preparing this report were limited to those specifically detailed
in the report and are subject to the scope limitations set out in the report.
The opinions, conclusions and any recommendations in this report are based on conditions encountered and
information reviewed at the date of preparation of the report. GHD has no responsibility or obligation to update this
report to account for events or changes occurring subsequent to the date that the report was prepared.
The opinions, conclusions and any recommendations in this report are based on assumptions made by GHD
described in this report (refer section 1.5 of this report). GHD disclaims liability arising from any of the assumptions
being incorrect.
GHD has prepared this report on the basis of information provided by Victorian Planning Authority and others who
provided information to GHD, which GHD has not independently verified or checked beyond the agreed scope of
work. GHD does not accept liability in connection with such unverified information, including errors and omissions
in the report which were caused by errors or omissions in that information.
The opinions, conclusions and any recommendations in this report are based on information obtained from, and
testing undertaken at or in connection with, specific sample points. Site conditions at other parts of the site may be
different from the site conditions found at the specific sample points.
Site conditions may change after the date of this report. GHD does not accept responsibility arising from, or in
connection with, any change to the site conditions. GHD is also not responsible for updating this report if the site
conditions change.
GHD | Victorian Planning Authority | 12548247 | Arden Transport Precinct 21.5 Assumptions
The following assumptions were made in preparation of the report:
– Operations and odours observed at the four industry’s during the time of GHD’s site visit (March and April
2021) are assumed to be representative of routine operations.
– Conditions observed during the odour surveillance program are considered to be representative of routine
operations.
– Information provided by each industry regarding plant equipment/ technology, operations, control measures
and complaint history is true and correct.
– The local meteorological data from the EPA operated automatic weather station (AWS) located at Footscray
is representative of the Precinct.
GHD | Victorian Planning Authority | 12548247 | Arden Transport Precinct 32. Site overview
2.1 Location and land use
The Precinct is located in North Melbourne and encompasses the land bordered by Macaulay Road, Dryburgh
Street and the Upfield rail corridor. The centre of the Precinct area, bordered to the west by the Citylink roadway
and Upfield rail line, is zoned Public Use (PUZ4 -Transport). The north of the Precinct includes Industrial Zone 1
(IN1Z) and Industrial Zone 3 (IN3Z) land. The Precinct also includes the North Melbourne Cricket Ground at the
North Melbourne Recreation Reserve, which is zoned for Public Park and Recreation (PPRZ) use. Mixed Use
zoned (MUZ) land is present to the east of the Precinct.
Currently, land uses within the Precinct are predominantly of an industrial nature. Land uses and infrastructure
includes transport, warehouses, flour mills, concrete and asphalt batching, automobile garages and laboratories. A
number of residences exist in the outer boundaries of the Precinct. Three parks exist in the Precinct; namely North
Melbourne Recreation Reserve, Clayton Reserve and Railway Place and Miller Street Park.
The Precinct is shown in Figure 2-1.
2.2 Surrounding land use
As referenced above, the Precinct is surrounded by Kensington to the northwest, West Melbourne to the
southwest and the balance of North Melbourne to the northeast and southeast. Kensington comprises mostly
general residential zones and parks, with some industry to the southeast. West Melbourne includes mostly
industrial development and public use zones for transport and ‘other’ use. The remainder of North Melbourne
consists of residential zones and mixed use zones.
2.3 Sensitive land use
The definition of a sensitive receptor or sensitive land use is defined by the EPA 5 as:
‘any land uses which require a particular focus on protecting the beneficial uses of the air environment
relating to human health and well-being, local amenity and aesthetic enjoyment, for example residential
premises, child care centres, pre-schools, primary schools, education centres or informal outdoor
recreation sites’.
Thus, the definition of sensitive receptor or sensitive land use is considered to be that identified by EPA for the
purpose of this assessment.
Current sensitive land uses within the Precinct include the residences located within the Mixed Use Zone located
on the eastern edge (which can be seen at Figure 2-1).
5
EPAV 2013 “Recommended separation distances for industrial residual air emissions” Publication. 1518, March 2013
GHD | Victorian Planning Authority | 12548247 | Arden Transport Precinct 42-1 Document Path: \\ghdnet\ghd\AU\Melbourne\Projects\31\12548247\GIS\Maps\Working\12548247-QGIS_Report figures.qgz Data Source: Google Earth Imagery 2021. Print Date: 22/04/2021 Created By: smateria ©2021. While GHD has taken care to ensure the accuracy of this product, GHD and DATA CUSTODIAN(S), make no representations or warranties about its accuracy, completeness or suitability for any particular purpose. GHD and DATA CUSTODIAN(S) cannot accept liability of any kind (whether in contract, tort or otherwise) for any expenses, losses, damages and/or costs (including indirect or consequential damage) which are or may be incurred as a result of the product being inaccurate, incomplete or unsuitable in any way and for any reason.
2.4 Constraining Industries
As identified earlier at Section 1.1, the GHD 2019 report identified four businesses with a separation distance in
accordance with EPA Publication 1518 that affects the Precinct.
The four industries and their recommended separation distance are as follows:
– Citywide – Asphalt plant - 208-292 Arden Street, North Melbourne (500 m separation distance)
– Holcim - Concrete Batching Plant - 77 Laurens Street, North Melbourne (100 m separation distance)
– Irwin Stockfeeds – Grain and stockfeed mill and handling facility - 1 Laurens Street, North Melbourne (250 m
separation distance)
– Weston Milling – Flour mill - 40 Laurens Street, North Melbourne (250 m separation distance)
From GHD 2019, it was found that there is currently insufficient separation between the four industries and the
existing sensitive receptors within and surrounding the Precinct; namely:
– There are a number of residential sensitive receptors located within the 500 m separation distance of Citywide
with the closest being approximately 220 m east of the Citywide plant along Macaulay Road. Other sensitive
uses closer include the North Melbourne Cricket Ground which also includes the North Melbourne Football
Club Headquarters and the North Melbourne Public Pool.
– There is just under 100 m separation from Holcim to the nearest residence along Munster Terrace.
– There are currently residential sensitive receptors located adjacent to the Weston Milling flour and
approximately 30 m east of along Munster Terrace.
– There are currently residential sensitive receptors located adjacent to the Irwin Stockfeeds site along
Anderson Street.
The above implies that in the event of an upset at the industries mentioned, a number of existing sensitive
receptors would be potentially exposed to a heightened risk of odour or dust impact.
2.5 Proposed future urban structure
The proposed future urban structure the Precinct is to comprise a mix of uses including residential, business
education and health. Figure 2-2 provides an indication of where sensitive uses are anticipated relative to the
existing adverse amenity separation distances of the four industries identified in section 2.4.
GHD | Victorian Planning Authority | 12548247 | Arden Transport Precinct 6Figure 2-2 Proposed Future Urban Structure (Provided by the VPA)
GHD | Victorian Planning Authority | 12548247 | Arden Transport Precinct 73. EPA Victoria Publication 1518
3.1 Overview
The EPA Victoria Recommended separation distances for industrial residual air emissions, 2013, Publication 1518
(EPA Separation distance guideline) provides advice on recommended separation distances between industrial
land uses that emit odour or dust, and sensitive land uses.
The guideline aims to support effective decision making regarding land uses, to:
– Protect local amenity
– Protect existing industry from encroachment by sensitive uses
– Prevent land adjacent to industry from being underutilised
3.2 Purpose
The EPA Separation distance guideline is a planning instrument used to provide recommended minimum
separation distances between sensitive land uses (i.e. residential, schools, hospitals and recreation reserves) and
industrial premises with the potential for off-site emissions (odour or dust) that can cause disamenity in the event
of an upset/malfunction (nuisance dust or odour). Equipment failure, accidents and abnormal weather conditions
are among the causes that can lead to emissions affecting sensitive land uses beyond the boundary of the source
premises. While it is an objective to eliminate emissions, even with the best of technologies and controls facilities
are not always guaranteed to achieve this 100% of the time.
The purpose of the guideline is as follows:
– Provide clear direction on which land uses require separation
– Inform and support strategic land use planning decisions and the consideration of planning permit
applications
– Prevent new sensitive land uses from impacting on existing industrial land uses
– Prevent new or expanded industrial land uses from impacting on existing sensitive land uses
– Identify compatible land uses that can be established within a separation distance area
It is noted that the separation distances outlined in the EPA Separation distance guideline are for
upset/malfunction conditions resulting in amenity impacts only, i.e. nuisance dust (deposited dust) and odour.
Emissions to air (odour or dust) occurring under routine operations should not be used to determine separation
distances as they are required to meet health standards.
Under routine operations the State Environment Protection Policy (Air Quality Management) (SEPP (AQM)) and
any relevant licence conditions (if the industry is a scheduled premises) should be met and odour/dust should be
confined on-site by the implementation of environmental management practices.
The EPA criterion for odour is given in Schedule A of the SEPP (AQM) as 1 odour unit (OU) at the 99.9th
percentile.
The health criteria are specified as design criteria (DC) in SEPP (AQM) where the DC for fine (PM10) and very fine
(PM2.5) particulates values of 80 and 60 μg/m3, respectively (based on a one hour average) are not to be
exceeded.
For so-called nuisance dust (i.e. unrestricted by size except able to be suspended in the air column) the criterion is
set in SEPP (AQM) as 330 μg/m3. It is the fractions of dust coarser than 2.5 or 10 micron that are likely to deposit
downwind – causing disamenity when settling on car bonnets, washing hung out to dry or window sills. A direct
measure of this impact is undertaken by some form of deposition gauge. This is integrated typically over a month
and a value of 4 g/m²/month (annually averaged) is used as a criterion for unacceptable disamenity.
Unlike routine emissions, unintended emissions are often intermittent or episodic and may originate at or near
ground level. Separation distances seek to avoid the consequence of upset industrial residual air emissions.
GHD | Victorian Planning Authority | 12548247 | Arden Transport Precinct 83.3 Agent of change principle
It is the responsibility of the ‘agent of change’ to provide evidence to the relevant authorities that a variation from
the recommended separation distances is appropriate. The EPA Separation distance guideline (Section 9) outlines
the ‘agent of change’ principle which is defined as the proponent of the proposed land use (i.e. change) that will
give rise to the consideration of separation distances. In this case the VPA is proposing sensitive land uses which
are considered the ‘agent of change’.
The EPA Separation distance guideline discusses the agent of change principle. It identifies six criteria to consider
(at Table 4 of the guideline) that allow for a site-specific variation to the default separation distances outlined in
Section 9 of the document. These criteria and an explanation for each criterion has been reproduced in Figure 3-1
below.
Figure 3-1 Criteria for site-specific variation (Table 4 of EPA Separation distance guideline)
3.4 Interface land uses
Section 10.2 of the EPA Separation distance guideline discusses interface land uses which describes land uses
that can be located within the specified separation distances (between industrial land uses and sensitive land
uses).
Table 5 in the guideline provides examples of interface land uses and their suitability (to be encouraged,
considered or prevented). Examples of interface land uses to be encouraged, which may be relevant to the
Precinct include business, recreation and conservation and public open spaces.
Interface land uses assist to reduce odour and dust impact dispersing from the industry to the sensitive receptor.
3.5 Application to the Precinct
Once an industrial facility’s operations and future intentions are known, the transition provisions in the EPA
Separation distance guideline can be used to sequence any proposed sensitive land use development within the
existing separation distance.
GHD has utilised the criteria outlined in the agent of change principle (as per section 3.3) to assess the
appropriateness of a variation to the four industry’s separation distances.
In particular, this assessment focuses on the following four criteria:
– Plant equipment and operation
– Likelihood of Industrial Residual Air Emissions (IRAEs)
– Environmental risk assessment
– Topography or meteorology
GHD | Victorian Planning Authority | 12548247 | Arden Transport Precinct 9As agreed with EPA at the inception meeting for this project, this assessment includes an empirical risk based
assessment to determine the likely risk of IRAEs having an impact out to the distance of the separation distance.
Under routine operations, the industries will be required to meet the EPA objectives of no offensive odours or
nuisance dust beyond the site boundary. Therefore, the assessment focuses on understanding the likelihood of
odour and dust emissions during an upset event. GHD considers that an empirical assessment using the Source-
Pathway-Receptor concept in conjunction with ‘ground truthing’ the site-specific experience is the most appropriate
method to determine the likely risk of odour and dust impact to the Precinct.
GHD | Victorian Planning Authority | 12548247 | Arden Transport Precinct 104. Overview of Industries
GHD undertook a site visit to inspect each of the four industries identified in section 2.4. The following sections
provides an overview of the operations and technology, emission controls, upgrades and historic performance at
each industry.
4.1 Citywide Asphalt Plant
GHD conducted a site visit of the Citywide asphalt plant accompanied by Citywide representatives on 31 March
2021. A summary of GHD’s observations during the site visit with regards to odour and dust is also provided within
this section.
4.1.1 Operations and technology
Asphalt operations have been occurring at the site since 1952. Citywide and Fulton Hogan commenced a joint
venture in 2016 to operate the asphalt plant. The current plant is a combination of Benninghoven and Amman
plants and was installed in 2007. The plant is similar to other asphalt plants currently operating across Victoria.
Typical operations occur between 6:00 am to 3:30 pm. However, if required the plant can operate 24 hours per
day.
Activities at the site involve producing warm mix asphalt (known as Greenpave) from sand and aggregates,
reclaimed asphalt pavement (RAP), lime, and bituminous materials. Greenpave is a warm asphalt mix and is a
climate sensitive alternative to traditional hot mix asphalt. The conventional hot mix asphalt process uses one
grade of bitumen at approximately 170°C. A reduction in production temperatures and fumes deliver immediate
safety benefits to workers and surrounding community stakeholders.
The operations at the site are as follows:
– Raw materials (aggregates) are trucked to site entering via Arden Street and unloaded in the storage bays
– A front end loader transfers the raw material into cold feed bins
– The bins supply calibrated quantities of each aggregate onto a cold feed conveyor belt that feeds a large
drum, which then dries and heats the blended material (rotating drum which tumbles the aggregate through
stream of hot air)
– Once heated, the blended aggregate is moved up the tower via a bucket elevator and regraded through a
screening process into hot aggregate storage bins prior to being weighed and dispatched into the pugmill and
mixed with a weighed quantity of bitumen and filler
– The asphalt product is then loaded into the delivery trucks from the base of the elevated pugmill
– If the site is busy, the asphalt is transferred via an enclosed conveyor to heated storage silos
4.1.2 Sources
Odour and dust emissions are expected to occur from:
– Dust emissions associated with the storage and handling of raw material (e.g. sand and aggregates)
– Odour from the asphalt mixing plant stack
– Fugitive odour emissions from the filling and storage of raw materials
– Fugitive odour emissions from finished product loading to trucks
GHD | Victorian Planning Authority | 12548247 | Arden Transport Precinct 114.1.3 Emission controls
The existing plant has been used in Australia for several years and there are currently seven in operation around
the country.
This particular asphalt plant has a number of emission controls and features which make it best practice for
environmental emissions, including:
– Aggregate and cold feed bins are covered with a roof, with high side walls to protect against wind generated
dust.
– The facility is fully paved to minimise the amount of dust generated by onsite truck activities.
– A sweeper is used daily to clean the paved area.
– To minimise dust generation, where possible most raw materials are received onsite damp.
– A high shade-cloth fence is installed around site perimeter, particularly in the aggregate area to help prevent
off-site dust from wind generation.
– Sensors installed on aggregate bins so bins do not overflow.
– An irrigation sprinkler system is installed at the raw aggregate bins and cold feed bins to dampen the raw
material when required.
– Dried aggregates are transferred to the mixing tower by an enclosed conveyor system to minimise dust
generation.
– Provides a fully enclosed production process from the cold feed bins to the final asphalt product to minimise
dust and odour generation.
– Storage of asphalt product is in enclosed silos to minimise odour generation.
– A reverse flow baghouse dust extraction system is attached to the drum dryer to remove combustion gases,
moisture and fine particles.
– A dye test is regularly undertaken to check baghouse for leaks.
– The bitumen tanks are bunded and insulated to reduce any odours.
– Odours from the bitumen storage tanks are controlled by an extraction system where the odours travel to a
water bath. The water bath results in the heavy molecules sinking to the bottom, whilst the lighter molecules
dissolve into the water.
– Filtered air from the baghouse is released to the atmosphere through an 18 m (above ground level) stack to
minimise ground level odour and dust generation.
– Any fines collected by the baghouse are transported to the filler silo via enclosed pipe screw conveyors and
available for reintroduction to the mixing process, thereby eliminating the disposal of this process residue.
– Odours from the truck fill are controlled by a dedicated secondary air extraction system focused on capturing
odour emissions generated during load out into trucks. Emissions are directed back into the aggregate dryer.
– All trucks are covered immediately with a tarpaulin after loading is completed to reduce odour emissions.
4.1.4 Management
The following management procedures are employed by Citywide to minimise emissions:
– Pre-start meeting in the morning with the production manager informed of any issues
– Monthly environmental checks - spot audit checks
– Quarterly boundary checks
– Annual checks of vapor tanks
– Environmental Management Plan in place
– Aspects and Impact Register in place
GHD | Victorian Planning Authority | 12548247 | Arden Transport Precinct 12All operations are monitored and controlled remotely from within the site. All items important to plant operation and
emission controls are monitored from the control room. In the event of a malfunction in any part of the plant, the
corrective actions can be implemented quickly and efficiently from the control room. The plant can be shut down
almost immediately in the event of equipment failure or operational upset, so the risk of extended upset conditions
is minimal.
The key to the efficient and effective operation of the plant and pollution control equipment is regular maintenance.
All components of the plant are regularly serviced in accordance with the preventative maintenance schedule.
4.1.5 Upsets events
Citywide confirmed that there have been no major upsets in the past 10 years leading to off-site impacts. This
suggests the site is well operated. In terms of possible upsets, it is considered by Citywide that a wind event
(strong winds during warmer weather) is the most likely upset pathway for dust emissions. However, with the
appropriate controls in place, a greater level of dust mitigation would be applied (i.e. increased watering) or dust
generating activities stopped in extreme cases. Hence the likelihood of dust generation from a wind event is
considered to be unlikely.
If the sprinkler system stops working, Citywide would call the street sweeper and other sources of water on site to
dampen material. In terms of plant breakdown, all operations would stop and discussions had with a dedicated
maintenance person, this is considered by Citywide to be the ultimate control. Breakdown of the plant would result
in a lower level of dust and odour emissions from the site due to lack of operations of the plant. Thus, this upset
condition does not result in dust or odour emissions hence no separation distance would be required for such an
event.
Other possible (but considered minor) upsets include:
– Lime silo overflow, considered unlikely due to controls in place (see section 4.1.3)
– Hole in baghouse sock, considered unlikely due to controls (see section 4.1.3)
4.1.6 Upgrades/continual improvement/future plans
The following upgrades have been implemented by Citywide to continually improve the site:
– When the joint venture came into place in 2016, crushing operations were removed from the site and
removed noisy parts of the plant
– In 2017/18 the bags within the baghouses were replaced
– In November 2018 a new secondary extraction system at the truck loadout area was installed
– In late 2020 the sprinkler system in the aggregate storage area was checked
In terms of future plans, the following was provided by Citywide:
– Proposed upgrade to the aggregate sprinkler system – Citywide is looking to install an automatic system that
would operate when certain wind speeds/directions are recorded
– No other future plant upgrades planned
– No commitments have been made for relocation at this time but are committed to continual improvements
4.1.7 Complaints and EPA notices
A complaint history from 2016 onwards was provided by Citywide. This included the following complaints in
relation to odour and dust.
– May 2018 - Resident complained about odour ~300-400 m away
– November 2018 - Odour complaint from the back fence (Citywide at Green Street), prompted Citywide to
install a new load out extraction system and the bitumen tank water bath
– September 2020 - Complaint about dust from CHEP (243 Arden Street North Melbourne) - was not 100%
attributed to Citywide and could be a result of the Metro tunnel / CYP concrete batching
GHD | Victorian Planning Authority | 12548247 | Arden Transport Precinct 13– October 2020 - Odour complaint from the reserve (possibly the basketball courts adjacent to the site),
Citywide checked the odour vapour recovery system
In terms of EPA interaction, the following was provided by Citywide:
– In October 2018 loose material was observed on Arden Road and EPA came to investigate. EPA issued a
notice in relation to dust. In response, Citywide installed a grate system which trucks drive over which collects
loose material.
– EPA noted that near the truck spray area (drivers spray the trucks to prevent material from sticking to the
trucks) there was a spill. In order to address this Citywide installed a bund for the chemical storage. This now
acts as a major spill capture system in the event of an emergency.
4.1.8 GHD’s observations
During GHD’s site visit, the site was considered to be clean and raw material stockpiles were damp with no dust
identified. In relation to odour, subtle odour was detected next to the bitumen tanks and an obvious but transient
odour next to an asphalt truck filling event.
4.1.9 Summary
Based on the above information the following conclusions can be made in relation to Citywide’s plant equipment
and operations:
– The technology/controls are considered ‘best practice’ with an exceptionally high standard of emission control
technology when compared to other similar asphalt plants in Victoria.
– A number of source-specific control measures in order to reduce odour and dust emissions have been
implemented.
– Continual plant upgrades have been implemented. These upgrades have resulted in an overall reduction in
odour and dust emissions.
– In addition to the source-specific controls a number of high-level management controls are implemented.
– Following past complaints, Citywide have implemented a number of controls in order minimise the likelihood
of the complaint occurring again.
– All potential upsets identified were deemed to have an unlikely likelihood of occurring.
– No upsets have been recorded over the last 10 years. Thus, at such a frequency of less than once in every
five years (e.g. once in every 10 years or greater), GHD’s experience indicates that a reduced buffer may be
appropriate.
– Based on the complaint data dating back to 2016, operations are not generating odour or dust complaints in
nearby residential areas and at existing receptors within the recommended septation distance. There are
currently residential sensitive receptors located approximately 220 m east of the plant. Other sensitive uses
closer include the North Melbourne Cricket Ground which also includes the North Melbourne Football Club
Headquarters and the North Melbourne Public Pool.
– GHD concludes that IRAEs from the plant are highly unlikely to occur.
4.2 Holcim Concrete Batching Plant
GHD conducted a site visit of the Holcim concrete batching plant accompanied by Holcim and Rail Project Victoria
(RPV) representatives on 12 April 2021. A summary of GHD’s observations during the site visit with regards to
dust is also provided within this section.
GHD | Victorian Planning Authority | 12548247 | Arden Transport Precinct 144.2.1 Operations and technology
Concrete batching operations have been occurring at the site for three years to support construction of the Metro
Tunnel Project. The plant is a mobile plant imported from Italy.
Typical operations occur between 5:00 am to 7:00 pm. However, if required the plant can operate 24 hours per
day.
The daily throughput depends on demand however an average throughput value is approximately 500 m³/day of
concrete.
The operations at the site are as follows:
– Raw material (aggregates) are unloaded in the storage bays
– A front end loader then transfers the raw material into a hooded weigh hopper which is connected to an
enclosed conveyor system which transports the material into the plant
– The cement is delivered by road tanker and pneumatically transferred from the sealed silos into the plant via
enclosed pipes
– The raw material (aggregates) is then mixed with the cement in an agitator and the concrete is then loaded
out into the concrete truck waiting below
– The concrete truck can then exit the site or drive to the wash out bay and add water to the concrete to make it
more workable
4.2.2 Sources
Dust emissions are expected to occur from:
– Dust generation from vehicle movement
– Delivery of raw materials
– Storage of raw material in bunkers and stockpiles
– Transfer of material to the batching plant
– Transfer of material by mobile plant, conveyors, hoppers and agitators
– Leakage or spills from silos
– Rupture of fabric filter
No odour emissions are expected to occur from the site.
4.2.3 Emission controls
The concrete batching plant is operated in accordance with EPA Publication 1806 Reducing risk in the premixed
concrete industry and has a number of emission controls and features which make it best practice for dust
emissions, including:
– Transport of raw materials:
• Raw materials are delivered wet/damp
– Hardstand surface:
• Site is fully sealed
• Site is cleaned daily by street sweeper
• Speed limit on internal unsealed roads enforced
– Ground level storage:
• Storage bays enclosed on three sides by solid walls
• Storage bays fitted shade cloth roof
• Storage bays fitted with sprinkler systems
• Storage bay stockpiles kept damp to maintain adequate moisture levels to prevent dust dispersion
GHD | Victorian Planning Authority | 12548247 | Arden Transport Precinct 15• Storage bay stockpiles kept at least 0.5 m below top of panels and inside open ends of bays
• Storage bay panel walls clearly indicate maximum fill height level and “Do not overfill” warnings
• Other ‘do not overfill’ management procedures in place and enforced
– Overhead silos
• Fitted with fully enclosed pneumatic transfers
• Fitted with emergency pressure alert and automatic cut-out overfill protection
• Fitted with dust filters
• Burst-bag detector system
– Transfer of sand and aggregate
• Front-end loader transfers prevent dust emissions by adequate moisture levels
• Weigh hopper fitted with a hood to capture dust
• Conveyor belts fully enclosed and hooded
• Dust extraction systems fitted around hoppers
– Agitator truck loading and wash down
• Loading bays roofed and enclosed with doors on one side
• Loading bays fitted with dust extraction systems
• Rubber loading socks used
• Trucks washed with water to remove all dust
4.2.4 Management
The following management procedures are employed by Holcim to minimise emissions:
– A checklist is in place which assists in identifying any issues ahead of time (e.g. check sprinkler system)
– Every three months (or earlier if required) the baghouse gets serviced
– Regular silo and filter inspections are undertaken
– An Environmental Management Plan is in place
All operations are monitored and controlled remotely from within the site. All items important to plant operation and
emission controls are monitored from the control room. In the event of any malfunction in any part of the plant, the
corrective actions can be implemented quickly and efficiently from the control room. The plant can be shut down
almost immediately in the event of equipment failure or operational upset, so the risk of extended upset conditions
is minimal.
The key to the efficient and effective operation of the plant and pollution control equipment is regular maintenance.
All components of the plant are regularly serviced in accordance with the preventative maintenance schedule.
4.2.5 Upsets events
Holcim confirmed that there have been no major upsets in the three years of operation resulting in off-site impacts.
This suggests that the site is well operated. In terms of possible upsets, the following was considered:
– A wind event (strong winds during warmer weather) is the most likely upset for dust. However, with the
appropriate controls in place, a greater level of dust mitigation would be applied (i.e. increased watering) or
dust generating activities stopped in extreme cases. Hence, the likelihood of dust generation from a wind
event is considered to be unlikely.
– Wind generated dust from failure of the sprinkler system. It would likely be identified in the checklist ahead of
time and Holcim would get it serviced as soon as possible. Thus, it was considered unlikely to occur.
– Baghouse filter blows a sock. This was considered unlikely as Holcim gets them serviced every three months
however if this were to occur they would get it serviced as soon as possible.
– Extraction system failure. Work would stop immediately and Holcim would get it serviced as soon as possible.
There would be no dust from the site due to operations ceasing.
GHD | Victorian Planning Authority | 12548247 | Arden Transport Precinct 164.2.6 Upgrades/continual improvement/future plans
Given the relatively new nature of the plant, no upgrades are proposed.
In terms of future plans, Holcim advises that the plant is expected to operate for a further 18 months (i.e. end of
2022) and will then be demobilised. It will take approximately two months to pack up/demobilise and relocate off
site.
4.2.7 Complaints and EPA notices
There have been no dust complaints and no interaction with the EPA.
4.2.8 GHD’s observations
During GHD’s site visit, the site was clean with no dust identified. Stockpiles of raw materials were damp.
4.2.9 Summary
Based on the above information, the following conclusions can be made about Holcim’s plant equipment and
operations:
– The technology/controls are considered ‘best practice’ with an exceptionally high standard of emission control
technology when compared to other concrete batching plants in Victoria.
– A number of source-specific control measures in order to reduce dust emissions have been implemented.
– In addition to the source-specific controls a number of high-level management controls are implemented.
– All potential upsets identified were deemed to have an unlikely likelihood of occurring.
– No upsets have been recorded over the three years of operation.
– No dust complaints have been made regarding the plant.
– The plant expected to operate for a further 18 months (i.e. end of 2022) and will then be demobilised.
– GHD concludes that IRAEs from the plant are highly unlikely to occur.
4.3 Weston Milling
GHD conducted a site visit of the George Weston Foods (GWF) Flour mill accompanied by a GWF representative
on 13 April 2021. A summary of GHD’s observations during the site visit with regards to dust is also provided
within this section.
4.3.1 Operations and technology
The flour mill has been operating at the North Melbourne site since 1856. The majority of mill equipment is from
the 1980s and 1990s, however this equipment is not dissimilar to what is currently available, with the main
advancements being in energy efficiency.
The mill operates 24 hours a day, seven days per week with trucks entering the site from 7:00 am to 11:00 pm.
The current throughput is estimated to be 90,000 tonnes per annum of wheat.
The operations at the site are as follows:
– Wheat is received by road tanker within a building where the wheat is unloaded into an intake pit in the
ground.
– The wheat is then transported to the bulk storage silos via an underground conduit connected to the pit.
– Wheat is then cleaned and screened. Aspiration (draw air through wheat) is undertaken. Water is then
sprayed on the wheat.
– Wheat then enters milling process where the grain kernels are broken open using rollers, after a series of
breaks the grain is sifted using sieving operations and air aspiration.
– The flour then passes through smooth reducing rollers.
GHD | Victorian Planning Authority | 12548247 | Arden Transport Precinct 17– The finished product (flour) is then stored in large bins onsite.
– Out loading is dispatched via bulk loading into tankers for removal by truck.
4.3.2 Sources
Dust emissions are expected to occur from:
– During wheat receival/tipping
– The pneumatic conveying system (positive and negative conveying) used throughout the milling process
– Out loading of flour
No odour emissions are expected from the site.
4.3.3 Emission controls
The flour mill has a number of emission controls and features which make it best practice for dust emissions,
including:
– The site is fully sealed to prevent dust
– The site is cleaned daily to prevent dust
– Receival and loadout is undertaken within an enclosed building with an openable roller door
– Ambient extraction systems are in place on sides of the intake pit when trucks tip wheat
– Burnley baffles exist within the pit to suppress dust when trucks tip wheat
– The milling process is fully enclosed within a building
– The milling process is connected to a large dust collection system – combination of cyclones (coarser
particles) and fabric filters (baghouses). Some quite large consisting of 100 socks.
– Differential pressure gauges monitor fabric filters for leaks/ baghouse failure
– Silos have dust collectors (three dust collectors in total and one exhaust/aspiration in main plant)
– Pneumatic process lines during milling have a large pressure through pipes which are fitted with over-clamps
so the pipes cannot move (clamps fitted over joining clamps to prevent separation)
– All pneumatic transfer end at a receiver where there is a dust collector which contains filter bags with a
500 g/m2 felt material used
– Stacks on roof serving each baghouse
– Trucks under negative pressure during flour loadout
– Load out has a dust extraction system
– Rubber socks fall down into the truck during loading to prevent dust
4.3.4 Management
The following management procedures are employed by GWF to minimise emissions:
– Every four months (or earlier if required) the baghouse gets serviced/checked
– Prompt clean up is undertaken of any flour accumulation
– Training is provided to all staff on dust explosions
– An Environmental Management Plan in place
All operations are monitored and controlled remotely from within the site. All items important to plant operation and
emission controls are monitored from the control room. In the event of any malfunction in any part of the plant, the
corrective actions can be implemented quickly and efficiently from the control room. The plant can be shut down
almost immediately in the event of equipment failure or operational upset, so the risk of extended upset conditions
is minimal.
The key to the efficient and effective operation of the plant and pollution control equipment is regular maintenance.
All components of the plant are regularly serviced in accordance with the preventative maintenance schedule.
GHD | Victorian Planning Authority | 12548247 | Arden Transport Precinct 18You can also read
